Ivan Lee Sweets, Sr. v. The State of Wyoming

HILL, Justice.

[11] Ivan Sweets was convicted of one count of obtaining property by false pretenses and one count of wrongful disposing of that property. He was sentenced to terms of six to eight years on each count, to be served consecutively. On appeal, Sweets challenges the sufficiency of the evidence to support his conviction for obtaining property by false pretenses, and he contends that the two criminal counts should have merged for purposes of sentencing.

[12] We affirm and, in so ruling, we overrule the "same facts or evidence test" for evaluating sentencing merger questions. The same…